How to develop a Covid-19 vaccination policy

by Inside Logistics Online Staff

As the Covid-19 pandemic continues to affect Ontario workplaces, employers are faced with the task of ensuring the safety of staff, clients and visitors while preparing to return to the workplace. In this effort, many public and private organizations have taken the initiative to implement Covid-19 vaccination policies.

The Public Services Health & Safety Association (PSHSA) has developed guidelines to help organizations develop and implement a Covid-19 vaccination policy.

In August 2021, the Ontario government made vaccination policies mandatory for organizations in high-risk sectors, such as hospitals, group living providers, post-secondary institutions and ambulance services. These employers have to ensure that employees are fully vaccinated or have a medical reason for not being vaccinated, and be regularly tested.

For other employers the decision to have a policy is their own. The PSHSA recommends considering factors such as the level of risk for various occupations in the workplace as well as the competing rights and interests at play.

Legal considerations

In Ontario, the Occupational Health and Safety Act does not address vaccination policies, but does specify in its regulations that employers must take every reasonable precaution to protect the health and safety of employees. Likewise the Canada Labour Code requires that companies in federally regulated industries do the same.

PSHSA points out that “although mandatory vaccination may not be a reasonable solution for every organization, adopting a vaccination policy can provide clarity to all workplace parties. Promoting vaccination may also support organizations during the pandemic by reducing employee absences due to illness, ensuring sustained workplace productivity, and improving workplace morale.”

Steps to follow

PSHSA suggests taking the following steps in developing a vaccination plan for your workplace:

Conduct a Covid-19 risk assessment

The assessment should take into account whether your workers need to have face-to-face interactions with co-workers or customers. Is a hybrid or work-from-home model possible? Do employees work in crowds for extended periods of time?

You also need to consider the safe practices available for each type of work to prevent exposure to the virus. For example, do staff engage in activities that require heavy breathing such as shouting, singing or aerobic exertion?

Does the workplace design promote safety or increase possible exposure? How close together do people work? Are there lots of shared surfaces that need to be frequently disinfected? Is PPE available?

Also, you need to assess what is known about transmissibility, spread and virulence of the virus.

PSHSA offers an infectious disease risk assessment (IDRA) tool that can help to develop an action plan for infectious disease hazard control.

Remember the internal responsibility system

Under Ontario laws everyone in the workplace has a role to play in keeping workplaces safe. Employers should design their Covid-19 workplace safety plans and vaccination policies to consider how everyone in the workplace can do their part to stop the spread.

Use the hierarchy of controls

While vaccinations mandates may be part of an overall strategy, they should not be used in isolation or to replace any other Covid-19 control measure. The PSHSA suggests using a layered approach using controls from each category in the hierarchy to ensure all hazards are addressed.

In the triangle diagram, effectiveness decreases the closer you get to the worker. The first controls work best because they do not rely on behavior.

Examples of each level are:

  • Elimination: move to a fully remote workforce, require ill workers to stay home, and implement screening to send sick people home.
  • Substitution: replace cleaning chemicals with ones strong enugh to kill the virus.
  • Engineering: improve ventilation, install filters that can stop the virus and add hand sanitzer stations.
  • Administrative: impleent policies and procedes including hand washng, training, cleansing, disinfectiong, vaccination and testing policies, contact free exchanges, staggered work hours.
  • PPE: Masks, gloves, face shields etc

Update anti-discrimination and harassment policies

Introducing covid-19 vaccination policies can have ripple effects on psychological health and safety hazards. This could mean an increase in harassment or discriminatory behavior if tensions escalate between vaccinated and unvaccinated groups. Policies should address how to report incidents and how they will be investigated.

Human rights considerations

As long as exemptions are allowed, vaccination mandates are permissible under the Ontario Human Rights Code, PSHSA says. Employers do need to be flexible to accommodate those using an exemption. Employers should also pay the costs of testing if that is part of the policy.


Employers must only collect information they require to fulfill a legitimate purpose. Current regulations support employers’ ability to implement a vaccine policy, and information is required to do so.

PSHSA has numerous resources for more information about covid-19 and vaccine policy. Visit